National Planning Policy Framework

Written evidence from The Theatres Trust

Response from The Theatres Trust: Summary

· The Theatres Trust does not believe that the NPPF gives sufficient guidance or gives local communities sufficient power over planning decisions in matters relating to culture, the arts and theatres. It needs to define culture and cultural faclities as an ‘asset of community value’ and within town centre uses.

· Our major concern is that without national guidance, at a local level, planners may overlook the contribution theatres and the performing arts make to the wellbeing and vibrancy of communities within their local plans.

· At an Inspectorate level as the NPPF is silent on culture our fear is that Inspectors will not consider the need for specific policies on culture, the arts and theatres in local plans, as they do currently.

· Theatres are vulnerable facilities and as the presumption will be in favour of those uses that are covered within the NPPF no matter how valued they are by the local community. Their protection and use will only be properly considered and protected if there is guidance on culture within the NPPF, which will give culture the same status as other uses.

· In our opinion the definition of ‘sustainable development’ contained in the document needs to be clearer on culture. The presumption in favour of sustainable development is not balanced or workable.

· The ‘United Cities and Local Governments’ (UCLG) approved in 2010 a policy statement recognising culture as the fourth pillar of sustainable development, next to economic growth, social inclusion and environmental balance. The Theatres Trust supports this view.

· At present leisure, sport and heritage are explicitly recognised within the draft NPPF. Culture, the arts and theatres are not. The reduction of policy guidance, particularly in relation to PPS4 in the new NPPF has meant that there is a lack of clarity surrounding culture, the arts and theatres and the role they play in achieving balanced sustainable development.

· The Trust does not consider that the core planning principles are clearly and appropriately expressed.

· We believe that culture is a core planning principle. Culture keeps the spirit of places alive and is essential to our wellbeing.

· Culture currently has its own policies distinct from leisure and sport in existing local planning policies and other national and regional plans. Cultural infrastructure is also referenced in the CIL Overview (2011). For coherence, clarity and to ensure that by its omission this does not lead to further complexity, culture must be included in the NPPF.

· In our opinion, the relationship between the NPPF to other national statements of planning-related policy is not sufficiently clear.

· PPS4 states that the main uses to which the town centre policies in the PPS apply are for ‘arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).’ The same strength of this policy is not carried forward into the NPPF.

· The policies on creating ‘sustainable communities’ should recognise that the planning system needs to deliver the right cultural facilities to meet local needs.

· The NPPF does not integrate national planning policy in respect of the Government’s commitment to culture and the arts and the sectors supported by the Department for Culture, Media and Sport (DCMS).

· The DCMS works with the Department of Health on ways that the arts can help improve wellbeing in the UK. Yet culture is not referred to within the NPPF under health and wellbeing.

· The DCMS works with DCLG on using the arts to regenerate local communities and recognises the important contribution that the arts make to the UK economy but there is no consideration of policies to support culture’s contribution to economic development within the NPPF.

· The Theatres Trust does not believe that the NPPF, together with the ‘duty to cooperate’ will provide a sufficient basis for larger-than-local strategic planning on culture.

· Theatre buildings not-in-theatre-use are at the greatest risk. The Theatres Trust is already concerned at the number of theatre buildings, particularly in the north of England, which are facing closure and demolition.

· Without concise NPPF policies that establish culture’s contribution to sustainable development The Theatres Trust fears the loss of theatre buildings in towns which already have little else in the way of cultural facilities.

· Where concepts of good spatial planning relate to vital national interests then we believe that there is a case for inclusion of culture in the NPPF and the Trust would argue that planning for culture is indeed of national interest.

· The Theatres Trust does not believe the NPPF is sufficiently evidence-based.

Response from The Theatres Trust

1) Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

2) The Theatres Trust does not believe that the NPPF gives sufficient guidance or gives local communities sufficient power over planning decisions in matters relating to culture, the arts and theatres.

3) The NPPF stresses the contribution planning can make to the economy, community wellbeing and the environment. It highlights the contributions to wellbeing made by sport, leisure, recreation and open spaces, the natural environment, and design. But it does not make any specific reference to the contribution that culture, the arts and theatres make to ensuring that communities thrive. From our perspective and remit ‘culture’ includes theatre and the performing arts.

4) The failure to make explicit mention of culture means that the NPPF’s treatment of the types of provision which are championed by the DCMS is unequal. Cultural facilities such as theatres, galleries, libraries, museums and archives have been viewed in the past by the planning system as public services, education facilities and community provision. The prominence and clarity given to sport and the historic environment in the draft NPPF and the failure to explicitly mention and define culture means that in relation to the DCMS sector the definition of sustainable development used in the framework is unbalanced.

5) Our major concern, therefore, is that at a local level, planners may overlook the need to consider the contribution theatres and the performing arts make to the vibrancy of communities and local centres within their local plan. An arts facility (for example, one supporting young people in productive cultural activities that deters them from crime) that does not fall easily into existing use classes or a theatre which is not statutory listed, could be demolished to make way for shops, offices and housing, leisure or sports facilities. Campaigners could try to argue a case for the building as an ‘asset of community value’ (which will come in with the new Localism Bill), but this would be a hard argument to make as within the local plan there will be no protection for such facilities.

6) Furthermore, because the NPPF does not define cultural uses as explicitly promoting sustainable development, other uses that the NPPF does promote will have a far stronger policy basis upon which to argue their case.

7) At an Inspectorate level, as the NPPF is silent on culture, our fear is that Inspectors will not insist on specific policy for culture, the arts and theatres in local plans. For example the London Borough of Islington Core Strategy Policy 14 had a sentence stating that ‘Existing cultural facilities will be promoted and protected’. During the Core Strategy Examination the Inspector decided to make a number of changes including replacing this sentence with stronger guidance ‘The council will protect and enhance the existing arts and cultural uses and encourage new arts and cultural uses, particularly within town centres’. The justification for the change was to clarify the approach to arts and culture. The Inspector also said that ‘A key issue for the Core Strategy is building on the Borough’s strengths as a cultural and arts destination. This change reinforces the relevant special objective ... to provide a clear strategic policy framework for protecting and developing such uses throughout Islington. It is endorsed to ensure effectiveness.’

8) It may be argued that inclusion of culture can be left to local plans, but theatres are vulnerable facilities and as the presumption will be in favour of those uses that are covered within the NPPF, no matter how valued they are by the local community their protection and use can only be properly considered and protected if there is guidance on culture within the NPPF which will give culture the same status as other uses.

9) Note that the site for the Aylesbury Waterside Theatre which was developed and secured by Aylesbury Vale District Council that the Planning Committee report specifically quoted the text on planning for cultural and tourism from PPS6 as a reason for supporting the granting of planning permission for the new theatre within the town centre. The venue has a 1,200-seat auditorium that converts into a 1,800-capacity hall for standing events, and a 225-seat suite for smaller events including dance, drama, meetings and conferences.

10) Is the definition of ‘sustainable development’ contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

11) In our opinion the definition of ‘sustainable development’ contained in the document is appropriate but the presumption in favour of sustainable development is not balanced or workable. This is because although the definition of sustainable development in the draft NPPF includes, for example‘…the need to create a good quality built environment with accessible local services that reflect the community’s needs and supports its health and wellbeing’ [para 10, bullet 3] we believe there is a need to strengthen the guidance by making explicit reference to culture at appropriate points in the text.

12) At present leisure, sport and heritage are explicitly recognised in the draft NPPF. Culture, the arts and theatres are not. The reduction of policy guidance, particularly in relation to PPS4 in the new NPPF has meant that there is a lack of clarity surrounding culture, the arts and theatres, and the role they play in achieving balanced sustainable development. This is particularly the case for theatres which are sui generis.

13) To achieve a less complex, balanced and accessible planning system, and one which promotes economic development and wellbeing, culture, the arts and theatre have to be recognised. This will provide clarity within local and neighbourhood planning and ensure there is sufficient guidance for the allocation and protection of land, buildings and facilities for cultural uses for those involved in development management.

14) Globally, local authorities recognise that culture is the fourth pillar of sustainable development. The ‘United Cities and Local Governments’ (UCLG), which represent over 1000 cities across 95 countries, and includes the Local Government Group in England, approved in 2010 a policy statement recognising culture as the fourth pillar of sustainable development, next to economic growth, social inclusion and environmental balance.

15) Are the ‘core planning principles’ clearly and appropriately expressed?

16) The Trust does not consider that the core planning principles are clearly and appropriately expressed and suggests that bullet 9; should include reference to ‘…taking account of and supporting local strategies for cultural provision’, as part of attempts to improve health and well being.

17) We believe that culture is a core planning principle. Culture keeps the spirit of places alive and is essential to our wellbeing. It enhances and improves the places in which we live and the quality of the lives of communities. The performing arts, in the broadest sense, contribute to people's happiness and wellbeing. Theatre’s ability to entertain, engage and involve is beyond doubt. Theatres also enable young people to demonstrate their skills and potential, and together with external partners help develop diverse programmes of arts activity that support individuals to develop an understanding of their responsibilities in society and moral compass regardless of background and personal circumstance.

18) The biggest current challenge facing arts organisations is to deliver more with less resources. The task for local authorities and arts organisations is to work together to identify and reach those most in need. Performing arts projects are often seen as soft targets for cuts, but it is these projects that are uniquely placed to provide sustainable benefits across society. The need for national policy on planning to include culture is in our view is essential if we are to achieve sustainable communities and enable them to expand and develop.

19) If culture is not included in the NPPF, local plans may not take account of cultural needs in forward planning to the detriment of the wellbeing of future communities. Culture currently has its own policies distinct from leisure and sport in existing local planning policies and other national and regional plans. Cultural infrastructure is also referenced in the CIL Overview (2011). For coherence, clarity and to ensure that by its omission this does not lead to further complexity, culture must be included in the NPPF.

20) Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

21) In our opinion, the relationship between the NPPF to other national statements of planning-related policy is not sufficiently clear. The chapter within the NPPF on ‘Business and Economic Development’ incorporates the current policies within Planning Policy Statement 4: Planning for Sustainable Economic Growth (PPS4). PPS4 importantly makes a distinction between leisure, and arts and culture. However the NPPF has lost all the references to culture, the arts and theatres. PPS4 contains important policies that help to promote and protect theatres in towns and cities.

22) At paragraph 7.4 (page 3) PPS4 states that the main uses to which the town centre policies in the PPS apply are for ‘arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).’ More explicitly, Policy EC4.2 (page 10) states: ‘Local planning authorities should manage the evening and night-time economy in centres.’ Policies should: ‘encourage a diverse range of complementary evening and night-time uses which appeal to a wide range of age and social groups, making provision, where appropriate, for leisure, cultural and tourism activities such as cinemas, theatres, restaurants, public houses, bars, nightclubs and cafes’.

23) The policies on creating ‘sustainable communities’ should recognise that the planning system needs to deliver the right cultural facilities to meet local needs. As stated in the ambition of the NPPF, we believe that it is through culture that we facilitate social interaction and inclusive communities.

24) The NPPF draft makes no reference to culture, the arts and theatres and therefore it cannot be considered to be sufficiently clear in these areas.

25) The NPPF does not integrate national planning policy in respect of the Government’s commitment to culture and the arts and the sectors supported by the Department for Culture, Media and Sport (DCMS). The Prime Minister’s speech on supporting economic growth highlights the creative industries as an important growth area in rebalancing the economy. The DCMS works closely with other Government departments and agencies to make sure that there is an appropriate level of support available for the creative industries. As stated in the Arts Council England’s 2011 paper on ‘Supporting growth in the arts economy’, ‘…our best arts and cultural infrastructure (the most open theatres, connected media centres and interdisciplinary art spaces) have become the ‘spikes’ and ‘intersections’ for creative exchange, operating at once as places (and digital spaces) of creative business transaction, inspirational cultural experience, education, and cross-sector innovation’. Yet the NPPF provides no policies on culture that match the DCMS’s ambitions.

26) The DCMS believes that the arts can help individuals and communities by bringing people together, strengthening relationships between local residents, welcoming differences and removing social barriers. It works with the Department of Health on ways that the arts can help improve wellbeing in the UK. Yet culture is not referred to within the NPPF under health and wellbeing.

27) The DCMS works with Department for Communities and Local Government on using the arts to regenerate local communities and recognises the important contribution that the arts make to the UK economy. It identifies issues that limit economic and artistic growth and works with the industry to overcome them. But there is no consideration of policies to support culture’s contribution to economic development within the NPPF.

28) Does the NPPF, together with the ‘duty to cooperate’, provide a sufficient basis for larger-than-local strategic planning?

29) The Theatres Trust does not believe that the NPPF, together with the ‘duty to cooperate’ will provide a sufficient basis for larger-than-local strategic planning on culture. Without any reference to culture, the arts or theatres in the NPPF it is not explicit that the duty-to-cooperate would cover these sectors, particularly where the future of national and regional theatre provision was at stake. Our concerns also lie in the extent to which cuts in local government will impact upon their capacity to cooperate with community groups who have the opportunity to take on ‘cultural’ assets of community value or who are seeking assurance that cultural and theatre provision with national, regional or local significance is included in neighbourhood and local plans.

30) In planning for spending cuts, arms length bodies and local authorities are already making provisions for reducing staffing levels and the cost of providing services in the areas of arts and culture, planning and conservation. They are looking at combining service functions with other arms length bodies and neighbouring authorities, and establishing trusts or outsourcing to deliver services. The impact of this disruption on theatres cannot be underestimated.

31) Theatre buildings not-in-theatre-use are at the greatest risk. The Theatres Trust is already concerned at the number of theatre buildings, particularly in the north of England, which are facing closure and demolition by local authorities that feel unwilling or unable to maintain them. The Palace Theatre in Nelson was demolished in 2009, while North Tyneside Council spent a considerable sum demolishing the Borough Theatre, Wallsend in 2010, and redeveloping it for commercial and residential uses, despite the efforts of local residents to save the building for cultural use.

32) Without concise NPPF policies that establish culture’s contribution to sustainable development The Theatres Trust fears that this would result in the loss of theatre buildings in towns which already have little else in the way of cultural facilities. The Opera House in Workington is the latest example where a local group is campaigning to see the theatre re-opened as an arts facility. The former theatre already has permission for demolition for a commercial development.

33) Where concepts of good spatial planning relate to vital national interests then we believe that there is a case for inclusion of culture in the NPPF and the Trust would argue that planning for culture is indeed of national interest.

34) Are the policies contained in the NPPF sufficiently evidence-based?

35) The Theatres Trust does not believe the NPPF is sufficiently evidence-based. If it was it would clearly reflect existing government policy supporting and promoting culture and the arts, as well as business development, the environment and community infrastructure.

The Theatres Trust

September 2011